Researcher Maya Forstater considers a recent Oxfam report which highlights the problem as to what constitutes corporate tax avoidance.
Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter, including withholding tax consultation, regulatory capital, changes to DOTAS, and penalties for the GAAR.
Amazon is now booking sales through a number of branches in Europe. Jonathan Cooklin and David Wilson (Davis Polk) consider what led to the change and the likely impact.
HMRC will be able to depart from its own guidance if it believes that tax avoidance might be involved, as the decision in Samarkand illustrates. Jeanette Zaman and Owen Williams (Slaughter and May) consider the uphill struggle that taxpayers could face to prove they have a substantive legitimate expectation.
Sandy Bhogal (Mayer Brown) highlights key features and potential issues
Nigel Doran (Macfarlanes) examines the new anti-avoidance rule
The paradox at HMRC, by James Brockhurst TEP (Lee Bolton Monier-Williams)
President Obama has proposed a levy for US corporations on profits located abroad, which are not repatriated to the US. Kristin Konschnik and Mitchell R. Kops (Withers) consider the proposals and what effect they may have in practice
David Whiscombe (BKL Tax) reports on the controversial new rules in this year's Finance Act in light of HMRC's new guidance.